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Issues:
1. Assessment of wealth-tax against individuals and Hindu undivided families. 2. Barred by time - Jurisdiction of Wealth-tax Officer. 3. Maintainability of writ petitions challenging assessment proceedings. Analysis: 1. The judgment of the High Court of Allahabad pertains to three writ petitions concerning the assessment of wealth-tax against individuals and Hindu undivided families for different assessment years. The petitioners are partners of a partnership firm, and the assessment proceedings were initiated based on their share in the firm. The Supreme Court had previously ruled that the interest of a karta of a Hindu undivided family in a firm is assessable to wealth-tax, justifying the reference made by the Wealth-tax Officer to the Valuation Officer. 2. The petitioners contended that the assessment proceedings had become barred by time, questioning the jurisdiction of the Wealth-tax Officer to continue with the assessment. The petitioners relied on a letter from the Wealth-tax Officer asserting that the proceedings were not time-barred. The preliminary objection raised by the Income-tax Department regarding the maintainability of the writ petitions was based on previous Supreme Court and High Court decisions emphasizing that issues of limitation should be raised before the relevant authorities and not in writ proceedings. 3. The petitioners argued that a writ of mandamus should be issued to restrain the Wealth-tax Officer from continuing the assessment proceedings. They relied on legal precedents, including Supreme Court and High Court decisions, supporting the issuance of writs in cases where an authority acts without jurisdiction. The court considered the arguments presented by both parties and ruled in favor of the petitioners, overruling the preliminary objection and admitting the writ petitions for further consideration. The court highlighted that the disputed questions raised did not require investigation of facts at that stage and that a prima facie case was made for restraining the Wealth-tax Officer from proceeding with the assessment. In conclusion, the High Court allowed the writ petitions to proceed, emphasizing the importance of jurisdiction and the possibility of issuing a direction to prevent unnecessary harassment in cases where an authority acts without jurisdiction. The court reserved its final opinion on whether the assessment proceedings were indeed barred by time, indicating that the issue would be examined in detail during the final hearing of the writ petitions.
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